Privacy Policy

a) Information You Provide

• Parent/Guardian account information: Name, email address, password (encrypted)
• Learner profile: Name or nickname, age, grade level, learning preferences, curriculum country
• Learning interactions: Questions asked, answers provided, exam responses, study progress
• Voice data: Audio input when using voice tutoring sessions (transcribed in real-time; transcripts retained — see Section 8 for retention)
• Support communications: Messages you send to our support team

b) Information Collected Automatically

• Device information: Device type, operating system, app version, unique device identifiers
• Usage data: Features used, session duration, interaction frequency
• Notification tokens: For push notification delivery
• Purchase data: See Section 3 below

c) Information We Do NOT Collect

• Credit card or bank account numbers
• Government-issued identification numbers
• Biometric data (fingerprints, facial recognition)
• Precise geolocation (GPS coordinates)

PopGamma offers optional Exam Packs available for purchase within the App. All purchases are processed entirely through Google Play Billing (Android) or Apple In-App Purchase (iOS). PopGamma does not collect, store, or have access to your payment card details.

What we collect in relation to purchases:

• Transaction identifier (to prevent duplicate charges)
• Pack type purchased (Starter, Standard, or Unlimited)
• Purchase date and expiration date
• Purchase environment (production or sandbox/testing)

Payment management: We use RevenueCat as an intermediary to manage purchase receipts and entitlements. RevenueCat receives transaction data from Google Play or Apple but does not receive your payment card information. See RevenueCat's privacy policy: https://www.revenuecat.com/privacy/

Refunds: All refund requests must be directed to Google Play or Apple. PopGamma does not process refunds directly.

We use your information to:

• Personalize learning: Adapt content to your learner's age, grade, curriculum, and learning progress
• Provide AI tutoring: Process questions and generate educational responses through our AI tutor, Prof. Albert
• Track progress: Enable parents to monitor their child's learning journey
• Send notifications: Growth updates, feature announcements, and account-related communications
• Improve our service: Analyze usage patterns to improve the App's educational quality
• Process purchases: Manage Exam Pack activation and usage tracking
• Prevent abuse: Detect and prevent fraudulent or unauthorized usage

We do NOT:

• Show advertising of any kind
• Sell personal data to third parties
• Create advertising or marketing profiles of children
• Use children's data for any purpose other than providing the educational service

PopGamma uses artificial intelligence to generate educational content, including explanations, quizzes, study cards, and exam evaluations. Please be aware that:

• AI-generated content may occasionally contain errors or inaccuracies
• Content is provided for educational purposes only and does not constitute professional advice
• Parents and guardians should supervise their child's use of AI-generated content
• We continuously work to improve the accuracy and quality of AI responses

PopGamma is designed for learners aged 6 and older, used under parental supervision. We take children's privacy seriously and comply with applicable children's privacy laws, including the Children's Online Privacy Protection Act (COPPA).

Our commitments:

• Parental consent required: A parent or legal guardian must create and manage the account
• Minimal data collection: We collect only the information necessary to provide the educational service
• No behavioral advertising: We never use children's data for advertising, profiling, or marketing
• No social features: Children cannot publicly share information, communicate with other users, or post content
• Parental access: Parents can review, modify, or delete their child's data at any time

If we learn that we have collected personal information from a child without verified parental consent, we will delete that information promptly.

Parents and guardians can exercise the following controls at any time:

• Review their child's learning data and progress through the App's Profile section
• Update their child's profile information
• Delete their child's profile and all associated learning data
• Request full account deletion by contacting contact@popgamma.com

Retention periods:

• Account data: Retained while your account is active. Deleted within 30 days of account deletion request
• Learning interactions: Retained while your account is active to provide personalized learning
• Voice data: Audio recordings are processed in real-time; transcripts are retained as part of learning interactions to support personalized tutoring
• Purchase records: Retained for the duration required by applicable tax and financial regulations (typically 7 years)
• Usage analytics: Aggregated and anonymized data may be retained indefinitely for service improvement

How to request deletion:

• In-app: Go to Profile → Settings → Delete Account
• By email: Send a request to contact@popgamma.com with the subject "Data Deletion Request"

We will process your deletion request within 30 days. Account deletion will permanently remove all learner profiles and learning history, forfeit any remaining Exam Pack quotas, and revoke access to all App features.

We implement industry-standard security measures to protect your information:

• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access controls: Role-based access limited to authorized personnel
• Authentication: Secure token-based authentication (Firebase JWT)
• Regular audits: Periodic security reviews and vulnerability assessments
• Incident response: Established procedures for detecting and responding to data breaches

While we strive to protect your data, no method of electronic transmission or storage is 100% secure. If you suspect unauthorized access to your account, please contact us immediately at contact@popgamma.com.

Your data is primarily stored on servers located in India. If you access PopGamma from outside India, your data may be transferred to and processed in India. By using the App, you consent to this transfer.

Where required by applicable law (such as the GDPR for users in the European Economic Area), we ensure appropriate safeguards are in place for international data transfers, including standard contractual clauses.

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data (see Section 8)
• Portability: Request your data in a structured, machine-readable format
• Objection: Object to certain processing of your data
• Withdraw consent: Withdraw previously given consent at any time

For users in the European Economic Area (EEA): We process your data based on consent (for optional features) and legitimate interest (for providing the educational service). You may contact your local Data Protection Authority if you believe your rights have been violated.

For users in California (CCPA): You have the right to know what personal information we collect, request its deletion, and opt-out of its sale. We do not sell personal information.

To exercise any of these rights, please contact us at contact@popgamma.com.

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date, notify you via email, and display an in-app notification. Your continued use of PopGamma after changes are posted constitutes your acceptance of the updated Privacy Policy.

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